E3Adventures takes bookings for Adventurous Activity trips/visits/activities from Schools and other organisations.
- For provision of Adventurous Activities in a school grounds there is no need to collect, from the school/organisation, personal information about the participants. Typically we do not unless there is relevant medical knowledge about a participant that the school/organisation shares in order to safeguard that participant.
- For provision of Adventurous Activities on a trip/visit in order to safeguard the participants we collect the names and medical information about participants that the school/organisation has booked (which the school/organisation has collected via their consent forms etc)
- Where it is appropriate for safeguarding reasons to link this information quickly to a participant where there might not be school staff readily available we take photos of the participants. This is primarily on a DofE expedition.
The type of personal information we collect
We currently collect and process the following information from the schools/organisations that book with us:
- Name of participant
- Any medical or behavioural information that the school/organisation feels appropriate to share that will help keep the participant (and other participants) safe.
- Photograph of participant in the group they are in (for example at the start of DofE expeditions)
How we get the personal information and why we have it
Information on participants provided by school/organisation:
- The name of participants and any medical information is provided by the school/organisation that book with us. We collect this information to safeguard the participants we work with and where appropriate conduct appropriate risk assessments based on the information provided. This could include food allergies or intolerances, it could also include a medical history where relevant.
Information on participants provided during trip/visit.
- On DofE expeditions where participants might be supervised by our staff remotely from school/organisation staff we take a photo of the group to quickly identify the group and members and link this to any medical information.
- In the event of an accident we might need to collect further information either directly from the participant or from their parent/guardian or from the school/organisation. This might have to be done quickly depending on the situation and consent is presumed by the action of the information being given.
We use the information that you have given us in order to safeguard participants
We may share this information within our organisation. We do not routinely share information provided to us with other organisations (in exceptional circumstances we might have to share information this might include, providing information to ambulance crew or police, RIDDOR reporting, reporting safeguarding concerns, reporting to HSE or similar following an accident)
- Information shared with us via from schools/organisations by email might be communicated within the organisation via email where appropriate.
- During the trip/visit we use WhatsApp groups that are specific to that trip/visit to share relevant information with staff that are on that trip/visit, this could include photos of participants.
Under the UK General Data Protection Regulation (UK GDPR), the lawful bases we rely on for processing this information are:
- Your consent. Through the process of booking with us we gain consent from the school/organisation to collect and hold this information, for the purposes described, in the way described. If you are unhappy with the information that we collect or the way we collect and manage it please contact the school/organisation that have booked with us in the first instance.
- Contract. We ask for this information from schools/organisations in order to effectively and efficiently fulfil the contract to deliver safe and effective management of participants on Adventurous Activities.
- We have a legal obligation to ensure that we appropriately deliver our higher duty of care to those in our charge, knowing their name and relevant medical / behavioural history is vital to this. In certain circumstances being able to identify participants without input from a 3rd party ( for example a school teacher) is also important in the exercise of that duty.
How we store your personal information
Your information is securely stored.
- Personal information (as described above) held on emails.
- Personal information held on WhatsApp. At the end of each trip/visit all staff are asked to delete the WhatsApp conversation and any information held from this. A pdf of the WhatsApp conversation is retained until the children in it have reached 21 years old (3 years from the date they reached the age of 18 and become an adult) as evidence of appropriate management and safeguarding of the trip/visit they attended.
Your data protection rights. Under data protection law, you have rights including:
- Your right of access – You have the right to ask us for copies of your personal information.
- Your right to rectification – Information held by us is a record of the information provided to us by the school/organisation, this does not imply that the information provided to us was correct or accurate but just a historical record of what was provided.
- Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances. Where this happens we will keep a record of the request and the outcome.
- Your right to restriction of processing – You have the right to ask us to restrict the processing of your personal information in certain circumstances.
- Your right to object to processing – You have the the right to object to the processing of your personal information in certain circumstances.
- Your right to data portability – You have the right to ask that we transfer the personal information you gave us to another organisation, or to you, in certain circumstances.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Please contact us at firstname.lastname@example.org if you wish to make a request.
How to complain
If you have any concerns about our use of your personal information, you can make a complaint to us at email@example.com You can also complain to the ICO if you are unhappy with how we have used your data. ICO website: https://www.ico.org.uk